MI| The State of Michigan Department of Insurance and Financial Services (DIFS) issued Bulletin 2025-15-INS to update and clarify the filing requirements for individual market medical plans for Plan Year 2026, superseding conflicting portions of a prior bulletin. The guidance, in response to new federal instructions and potential Congressional actions, requires issuers to submit two sets of rates—Primary and Secondary—based on different assumptions about federal funding for cost-sharing reductions (CSR) and premium tax credits. The bulletin also amends submission timelines and details documentation expectations for actuarial support of rate changes.
Key Points:
- Issuers must submit two sets of rates and justifications: “Primary” (assuming no Congressional appropriation for CSR payments and expiration of enhanced premium tax credits) and “Secondary” (assuming CSR appropriations but expiration of enhanced tax credits).
- The revised timeline requires Forms and Binders by May 28, 2025, and both sets of Rates by June 16, 2025, with separate filings for each.
- Actuarial Memoranda for both rate sets must detail the methodology and impact of subsidy changes, and issuers must include actual CSR amounts paid for 2024 in their documentation.